Transcript Document

NSPS Regulations Update
Angela Marconi, P.E., BCEE
Manager of Landfill Gas Systems
Delaware Solid Waste Authority
**WARNING**
2
Introduction & Background
• New Source Performance Standards (NSPS)
• Existing Guidelines (EG) and Compliance
Times for Municipal Solid Waste Landfills
• Current NSPS & EG were both issued March
12, 1996
• They are subparts:
– WWW (NSPS)
– Cc (EG)
3
Introduction & Background
• On July 17, 2014 a proposed new NSPS
(subpart XXX) & ANPRM were issued
• Advanced Notice of Proposed Rulemaking
(ANPRM) for the revised EG
• SWANA submitted comments on both
September 15, 2014
• EPA plans to finalize the NSPS 2015
• EPA plans to propose the EG 2015 and
finalize it in 2016
4
5
Applicability
• Subpart XXX will apply to landfills that are
newly constructed, modified or
reconstructed after July 17, 2014
• Once final, the EG may include many
Subpart XXX requirements that will apply
to existing landfills
6
Proposal
• Subpart XXX contained an extensive
preamble requesting answers to questions
and requests for suggestions
• ANPRM was “all preamble”
• RED = proposed
• GREEN = questions
• BLUE = SWANA comments
7
Threshold Reduction
40 MG/yr. NMOC
8
Treatment
• Prescriptive Requirements Proposed:
– 10 microns for filtration systems
– 45°F for temperature
– Continuous monitoring at 15 minute intervals
using 24 hr. avg. to monitor pressure drop for
filtration and dew point drop for temperature
9
Treatment
• Temperature requirement is an increased burden
• Majority of projects do not require chillers; addition
is major cost
• Pretreatment should be based on equipment
manufacturer guidelines
• SWANA: No continuous monitoring requirement;
compliance through operations and maintenance
records in semi-annual reports
10
Wellhead Standards
• Proposed: Maintain existing performance
standards for temperature and oxygen or
nitrogen
• Comment: Eliminate standards; can hinder
efficient operation of GCCS and hamper
emission reductions
11
Wellhead Standards
• Reduce oxygen & temperature monitoring
frequency?
• Adjust monitoring frequency only for
beneficial use sites?
• Require automated wellhead monitoring?
• Additional parameters?
12
Best System of
Emission Reduction
• Proposed: Well-designed and operated
GCCS is best system of emission
reduction (BSER)
• Comment: Agree with definition of BSER
– Prescriptive requirements counter to BSER
– Open/non-enclosed flares should remain
BSER
13
Surface Emissions Monitoring
• Preamble Clarification: SEM is required at
every penetration
• Comment: This has not been the previous
policy
• Targeted approach where problems are likely
– Visual or olfactory observation (e.g., stressed
vegetation)
– Clarification Requested: Monitoring every
penetration not required under WWW
14
Surface Emissions Monitoring
• Solicitation of information to bring SEM to
look more like the California Landfill Methane
Rule (LMR)
– Tighter walking pattern & integrated monitoring?
– Incorporate wind speed restrictions for SEM?
• Comment: Maintain WWW SEM criteria
– Data from California has shown minor benefits of
enhanced SEM does not warrant the effort/cost.
• EPA estimated annual cost increase of $50,000 to
$362,900
– 73% of sites have requested a weather variance
15
Surface Emissions Monitoring
• Remote measuring & monitoring?
–
–
–
–
–
–
–
–
–
Radial plume mapping
Optical remote sensing
Fourier Transform Infrared spectroscopy
Cavity ringdown spectroscopy
Tunable diode laser
Tracer Correlation
Micrometerological eddy-covariance
Static flux chamber
Differential absorption
16
Surface Emissions Monitoring
• Comment: Maintain current SEM as BSER
– Enhance monitoring significant increased cost
– Implementation & logistical issues
– These are research tools only
17
Startup, Shutdown & Malfunction
• Proposed: Eliminate 1-hour and 5-day
downtime criteria; NSPS applies at all times
• Comment: The nature of landfills makes this
impossible to meet
– Only emission standard: reducing NMOC by 98%
– Landfill a sponge if GCCS down, emissions not
automatic
– Difficult to quantify emission exceedances
18
Startup, Shutdown & Malfunction
• Practical Impact of SSM Elimination:
– 5-Day provision gone; GCCS downtime could be
a deviation
– 1-Hour provision gone; device downtime could be
a deviation
– Device temperature variations during
startup/shutdown could be a deviation
– Enhanced enforcement/fines/chronic violation
– Permit/Title V issues
19
Closed & Non-Producing
• Proposed: Actual data rather than
estimated emissions criteria for meeting
1% NMOC GCCS removal
• Comment
– Support use of actual data
– Additional flexibility needed for closed/nonproductive sites
20
Closed & Non-Producing
• Clarify NSPS to apply to closed areas of
active landfills
• NSPS 15 year removal date from initial well
installation, not NSPS/EG performance test
• Annual SEM for closed areas of active
landfills
• Tier 2,3,“4” allowed at any time to defer
NSPS
21
Tier 4
• “Tier 4” for determining when GCCS is
installed?
• Comment: Support “Tier 4” procedure
– Using SEM to determine installation
requirement
– Allow non-producing areas of active landfills
– Use a similar step-down to exit NSPS
22
Definition of Household Waste
• Proposed: Excludes segregated yard
waste; preamble clarifies C&D as not in
HHW definition
• Comment: Support segregated yard waste
exclusion; recommend C&D clarification
added to definition
23
Additional Items
• NSPS
– Design plan approvals
– Test Methods 18 & 25A removed from use
• ANPRM
–
–
–
–
–
Waterlogged wells
Redundant seals & enhanced sealing materials
Biocovers/biofilters
Emissions modeling
Organics Diversion
24
Summary
• Stay tuned for final XXX and proposed EG
• When the rules come out read them (or
assign this to a subordinate)
25
Questions?
Angela Marconi: [email protected]
Manager of LFG Operations, Delaware Solid Waste
Authority
26